Allowing the petition the Court held that the return of income was filed by the assessee in response to notice under section 148 on January 7, 2020 and on January 8, 2020 reasons were sought. On January 10, 2020, the reasons were supplied and on March 4, 2020, the assessee filed its objections. These objections were disposed of only on July 23, 2021 after a period of one year and four months. There was nothing that prevented the Assessing Officer to have called for objections, assigning a time limit to the assessee to file them, and disposing of the objections expeditiously. The notice under section 148 dated December 12, 2019, the order dated July 23, 2021 and the reference to the Transfer Pricing Officer on November 24, 2020 stood vitiated by the non-issue of notice under section 143(2) of the Act and were liable to be quashed. (AY.2016-17)